Title
Rosca vs. Alikpala
Case
G.R. No. L-22088
Decision Date
Jun 30, 1964
Police officers challenged their termination after refusing qualifying exams; court ruled reinstatement valid only against Civil Service Commissioner, not city officials, due to jurisdictional limits.
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Case Digest (G.R. No. L-22088)

Facts:

  1. Parties Involved:

    • Petitioners: Celestino C. Rosca, et al., officers and members of the Caloocan City Police Department.
    • Respondents: Hon. Federico C. Alikpala (Acting Commissioner of Civil Service), Mayor, Acting Chief of Police, Treasurer, and Auditor of Caloocan City.
  2. Background:

    • Petitioners filed a petition for prohibition and injunction on July 19, 1963, before the Court of First Instance of Manila.
    • They alleged that the Acting Commissioner of Civil Service re-examined their official status and ordered them to take qualifying examinations for their respective ranks.
    • Petitioners refused to take the examinations, leading to the termination of their services on June 21, 1963, via a letter from the Acting Commissioner to the Caloocan City Mayor.
  3. Petitioners' Claims:

    • They sought a declaration that their demotion and termination were illegal.
    • They prayed for an injunction to prevent the respondents from enforcing the termination and to restore them to their positions with full back pay.
  4. Court Proceedings:

    • On July 25, 1963, the court issued an order for respondents to show cause why the injunction should not be granted.
    • On August 5, 1963, the court issued a preliminary injunction, ordering the restoration of petitioners to their positions and payment of salaries as if no interruption occurred.
    • On August 8, 1963, the court modified its order, eliminating the mandatory injunction against Caloocan City officials due to lack of territorial jurisdiction.
  5. Petitioners' Appeal:

    • Petitioners filed a petition for certiorari, seeking to reinstate the full order of August 5, 1963, including the mandatory injunction against Caloocan City officials.

Issue:

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Ruling:

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Ratio:

  1. Territorial Jurisdiction of Courts:

    • Courts of First Instance can only issue injunctions for acts committed within their territorial boundaries. Actions requiring enforcement outside their jurisdiction are beyond their authority.
  2. Effect of Oversight in Court Orders:

    • An oversight in a court order, such as the unintended elimination of a mandatory directive, can be corrected by the appellate court to ensure justice and proper implementation of the law.
  3. Role of the Civil Service Commissioner:

    • The Acting Commissioner of Civil Service, having initiated the re-examination and termination of petitioners, was the key party responsible for their reinstatement and payment of salaries. A directive against him was sufficient to achieve the desired relief, making a similar directive against Caloocan City officials unnecessary.


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